1. Personal Data Protection Law

Personal Data Protection Law No. 6698 (KVKK) was adopted on March 24, 2016, and published in the Official Gazette No. 29677 dated April 7, 2016. Some parts of the KVKK entered into force on the date of publication, while others entered into force on October 7, 2016.

2-B TEXTILE IND. TUR. CONST. TRADE. ITH.VE IHR. LTD. ŞTİ. (Company) is the data controller within the scope of Article 3, paragraph 1, subparagraph (ı) of Law No. 6698 on the Protection of Personal Data. The electronic system used by the company to collect and process information within the scope of Article 3, paragraph 1, subparagraph (h) of the Personal Data Protection Law is the Data Recording System. The company collects personal data for specific, explicit, and legitimate purposes and processes it by structuring it according to specific criteria. Within the scope of Article 3, paragraph 1, subparagraph (ğ) of the Personal Data Protection Law, both the company entity and its employees serve as data processors.

1. Purpose of Policy

Personal Data Protection Policy has been prepared to determine the procedures and principles regarding the work and transactions related to data storage operations carried out at 2-B TEKSTİL SAN. TUR. İNŞ. TİC. İTH.ve İHR. LTD. ŞTİ.

The Company prioritizes processing personal data belonging to its customers, employees, job candidates, service providers, visitors, and other third parties in accordance with the Constitution of the Republic of Turkey, international agreements, Personal Data Protection Law No. 6698, and other relevant legislation, and ensuring that data subjects can effectively exercise their rights. All actions and procedures related to the storage and destruction of personal data are carried out in accordance with the Policy prepared by the Company accordingly.

1. Scope of the Policy

Personal data of customers, Company employees, job candidates, service providers, visitors and other third parties are within the scope of this Policy, and this Policy applies to all recording environments and personal data processing activities owned or managed by the Company.

1. Definitions

Anonymization: Making personal data in such a way that it cannot be associated with an identified or identifiable Natural person in any way, even by matching it with other data.

Explicit Consent: Consent related to a specific subject, based on information and expressed with free will.

Relevant Person: The natural person whose personal data is processed.

Personal Data: Any information relating to an identified or identifiable natural person.

Processing of Personal Data: Any operation performed on data, such as obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over, making available, classifying or preventing the use of personal data, either fully or partially by automatic means or non-automatic means provided that it is part of any data recording system.

Data Processor: Natural or legal person who processes personal data on behalf of the data controller based on the authority granted by the data controller.

Data Recording System: A recording system in which personal data is structured and processed according to certain criteria.

Data Controller: The natural or legal person who determines the purposes and means of processing personal data and is responsible for establishing and managing the data recording system.

Law/KVKK: Personal Data Protection Law No. 6698.

Deletion of Personal Data: Deletion of personal data; rendering personal data inaccessible and reusable for Relevant Users in any way.

Destruction of Personal Data: The process of making personal data inaccessible, irretrievable and reusable by anyone.

Special Personal Data: Data regarding individuals’ race, ethnic origin, political opinion, philosophical belief, religion, sect or other belief, appearance and dress, membership of associations, foundations or unions, health, sexual life, criminal convictions and security measures, as well as biometric and genetic data.

1. Processing of Personal Data2-B TEXTILE IND. TUR. CONST. TRADE. ITH.VE IHR. LTD. ŞTİ. processes the personal data of natural persons in accordance with Articles 4 and 5 of the Personal Data Protection Law. In this context, it collects and processes the data of its customers, employees, and other natural persons with whom it has contact within the scope of its business relationship. The Company is responsible for processing and protecting the data of natural persons with whom it has contact within the scope of Personal Data Protection Law No. 6698 and related legislation.

The Company processes personal data within the scope of subparagraphs (a), (b), (c), (ç), and (d) of the first paragraph of Article 4 of the Personal Data Protection Law (KVKK). The Company processes personal data;

Processing in Accordance with Law and Fairness: The Company acts in accordance with the principles established by legal regulations and general rules of trust and fairness in the processing of personal data. In this context, the Company does not use personal data for purposes other than those for which it is processed.

Ensuring that Personal Data is Accurate and, when Necessary, Up-to-Date: The Company ensures that the personal data it processes is accurate and up-to-date, taking into account the fundamental rights of personal data owners and its own legitimate interests.

Processing for Specific, Clear, and Legitimate Purposes: The Company clearly and precisely identifies its legitimate and lawful purposes for processing personal data. The Company processes personal data in connection with, and to the extent necessary for, the domain name and other services it offers.

Being Relevant, Limited and Proportionate to the Purpose of Processing: The Company processes personal data in a manner suitable for the achievement of the determined purposes and avoids processing personal data that is not relevant or needed to achieve the purpose.

Retention for the Period Specified by Relevant Legislation or Necessary for the Purpose of Processing: The Company retains personal data only for the period specified in relevant legislation or necessary for the purpose of processing. Upon expiration of this period or the elimination of the reasons requiring processing, personal data is deleted, destroyed, or anonymized by the Company. Personal data and documents obtained in domain name transactions and other transactions are retained in the database and backup system for the necessary period of time, and are available to the relevant courts upon request in the event of any disputes.

1. Enlightening and Informing the Personal Data Owner

In accordance with Article 10 of the Personal Data Protection Law, the Company provides information to data subjects during the collection of personal data. A general information text is also available at www.lugga.com.tr. In this context, the Company provides information on the identity of the data controller, the identity of their representative, if any, the purposes for which personal data will be processed, to whom and for what purposes the processed personal data may be transferred, the method and legal basis for personal data collection, and the rights of the data subject, based on the nature of the data subject and the data processing process. This policy, along with a cookie policy, a general information text, a privacy policy, and explicit consent texts and information texts in areas where customer information is collected, are available on the Company’s website.

1. Deletion, Transfer or Anonymization of Personal Data

Data collected and processed by 2-B TEXTILE SAN. TUR. İNŞ. TİC. İTH.ve İHR. LTD. ŞTİ. must be deleted or anonymized within certain timeframes in accordance with the Personal Data Protection Law and the Regulation on the Deletion, Destruction, or Anonymization of Personal Data. Retention periods may vary depending on the nature of the data and the activities carried out by the company while processing the data.

Personal data and documents obtained during the allocation of certain domain names and other services are stored in the database and backup system for the required period of time in order to be submitted to the relevant courts upon request of the courts in possible cases.

Personal data kept in the company database is not transferred anywhere in the country or abroad.

1. Data Owner Rights

The rights of real persons whose personal data is processed, pursuant to Article 11 of the KVKK, are as follows:

To learn whether personal data has been processed, To request information if personal data has been processed, To learn the purpose of processing personal data and whether it is used in accordance with its purpose, To know the third parties to whom personal data has been transferred, both domestically and abroad, To request correction of incomplete or inaccurate personal data and to request notification of the action taken in this context to third parties to whom personal data has been transferred, To request the deletion or destruction of personal data if the reasons requiring processing are no longer necessary, despite the data having been processed in accordance with the provisions of the Personal Data Protection Law and other relevant laws, and to request notification of the action taken in this context to third parties to whom personal data has been transferred, To object to the analysis of processed data exclusively through automated systems, leading to a result detrimental to the person, To request compensation in the event of damages incurred due to the unlawful processing of personal data. To exercise your rights specified above, you can apply to 2-B TEKSTİL SAN. TUR. İNŞ. TİC. İTH.ve İHR. LTD. ŞTİ. by writing a petition containing your request and your contact information. Your request will be finalized within 30 (thirty) days at the latest.

1. Contact Information

Company Address: LUGGA BOUTIQUE HOTEL

Müskebi Neighborhood Eren Street No:12 Bodrum/Muğla/Türkiye